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NO. 03-14-00535-CV 

___________________________________________________

IN THE COURT OF APPEALS

FOR THE THIRD DISTRICT OF TEXAS

AT AUSTIN, TEXAS

___________________________________________________

David Young,

Appellant,

v.

Trails End Homeowners Association, Inc., TLS Properties, Ltd., 

TLS Operating Company, LLC, Van Keene and Rick Durapau,

Appellees.

On Appeal from the 200th Judicial District Court of Travis County, Texas

(Honorable Scott H. Jenkins, of the 53rd Judicial District Court, Presiding)

Trial Court Cause No. D-1-GN-10-003864

AMENDED JOINT AND UNOPPOSED MOTION FOR 

EXTENSION OF TIME TO FILE APPELLEE’S BRIEFS

TO THE HONORABLE COURT OF APPEALS:

COMES NOW Appellees Trails End Homeowners Association, Inc., 

TLS Properties, Ltd., TLS Operating Company, LLC and Van Keene 

(“Appellees”), and file this Amended Joint and Unopposed Motion for 

Extension of Time to File Appellee’s Briefs, seeking a 30 day extension of 

time in which to file their briefs, thereby extending the deadline of April 22, 

2015, up to and including May 22, 2015.

ACCEPTED

03-14-00535-CV

4953214

THIRD COURT OF APPEALS

AUSTIN, TEXAS

4/20/2015 1:48:55 PM

JEFFREY D. KYLE

CLERK
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1. Appellant’s brief was originally due on or about December 19, 

2014. After obtaining three separate extensions, Appellant’s deadline was 

ultimately extended to March 18, 2015, when it filed its brief. Upon the 

Court’s instruction, Appellant filed a corrected version of their brief on 

March 23, 2015. As a result, the current deadline for Appellees to file their

briefs is April 22, 2015.

2. Pursuant to Rules 10.5(b) and 38.6(d), of the Texas Rules of 

Appellate Procedure, Appellee seeks a twenty (30) day extension of time in 

which to file their briefs, thus extending the deadline up to and including 

May 22, 2015. 

3. Appellees seek the requested extension of time because

Appellee’s agreement to extend Appellants’ deadline to file its brief on at 

least two occasions resulted in Appellee’s deadline to fall at a time when its 

lead trial and appellate counsel’s travel schedule has been burdened with 

personal and professional activities– both within and outside the State of 

Texas – that command significant expenditures of time. 

4. Appellees have not requested any previous extensions of time in 

this proceeding. This motion is filed in good faith and is not sought for 

purposes of obstruction or delay, but rather is requested so that justice may 

be done. 
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5. No party, including Appellant, opposes the extension. After 

conferring, all parties have agreed to the relief requested herein.

6. WHEREFORE PREMISES CONSIDERED, Appellees

respectfully request that the Court grant their joint and unopposed motion 

to extend the time to file their briefs by thirty (30) days to and including

May 22, 2015.

Respectfully submitted,

JACKSON WALKER L.L.P.

By: /s/ Christopher R. Mugica

Christopher R. Mugica

State Bar No. 24027554

cmugica@jw.com

Emilio B. Nicolas

State Bar No. 24058022

enicolas@jw.com

100 Congress Avenue, Suite 1100

Austin, Texas 78701

(512) 236-2000

(512) 236-2002 – Fax

and
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W. Thomas Buckle

State Bar No. 03299000

tbuckle@sbylaw.com

Jeff Tippens

State Bar No. 24009121

jtippens@sbylaw.com

Scanlan, Buckle & Young, P.C.

602 West 11th Street

Austin, Texas 78701

(512) 478-4651

(512) 478-7750 – Fax

ATTORNEYS FOR APPELLEE 

TRAILS END HOMEOWNERS 

ASSOCIATION, INC. AND VAN 

KEENE

STRASBURGER & PRICE, LLP

By: /s/Derek Quick

Derek Quick

State Bar No. 24072471

derek.quick@strasburger.com

720 Brazos Street, Suite 700

Austin, Texas 78701

(512) 499-3600

(512) 499-3660 - Fax

ATTORNEYS FOR APPELLEES 

TLS PROPERTIES, LTD. AND 

TLS OPERATING COMPANY, 

LLC
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CERTIFICATE OF CONFERENCE

In accordance with Rule 10.1(a)(5) of the Texas Rules of Appellate 

Procedure, this is to certify that on April 16, 2015 the undersigned counsel 

for Appellees Trails End Homeowners Association, Inc. and Van Keene 

conferred with counsel for Appellant regarding the merits of the foregoing 

motion, and Mr. Casey indicated that he agrees with the relief requested 

therein. Furthermore, on April 20, 2015 the undersigned counsel also 

conferred with Pro Se Appellee, Rick Durapau regarding the merits of the 

foregoing motion, and Mr. Durapau indicated that he agrees with the relief 

requested therein.

/s/ Christopher Mugica

Christopher Mugica 
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CERTIFICATE OF SERVICE

This is to certify that on this 20th day of April, 2015, a true and correct 

copy of the above and foregoing document was electronically mailed to the 

parties registered or otherwise entitled to receive electronic notices in this 

case pursuant to the Electronic Filing Procedures in this Court and/or via 

electronic mail upon:

Stephen Casey

Casey Law Office, P.C.

595 Round Rock West Drive, Suite 102

Round Rock, Texas 78681

Stephen@caseylawoffice.us

Rick Durapau, Pro Se

11907 Misty Brook Drive 

Austin, Texas 78727 

rdurapau@gmail.com

/s/ Christopher R. Mugica

Christopher R. Mugica

12989071v.3